1. Technological Field
This disclosure relates generally to systems and methods of citation, and in one exemplary aspect to citation for documents such as legal decisions and other types of written materials, whether in hardcopy or electronic (e.g., electronically-captured) format.
2. Description of Related Technology
Generally, document citation systems include information to identify the document, such as case name, title, court, author, date, publication in which the document is published, and combinations of these. As used herein, the term “document” refers without limitation to hardcopy (e.g., paper) documents, electronic documents such as pdf formatted documents, HTML or XML renderings, images, virtual or on-line documents, and other human-perceivable renderings. These document citation systems also generally include information to locate specific text within the document, such as a page number. For example, a commonly used citation system for legal decisions from the state and federal courts of the United States utilizes a reporter-based system in which the legal decisions issued by the various courts are gathered and published in various reporters, such as Westlaw™ or BNA™ reporters.
The citation for legal decisions generally includes the case name, the name of the court issuing the decision, a date or year of the decision, the volume number for the reporter, the page number in the reporter where the decision starts, and to locate specific text within the decision a second page number often referred to as a “pinpoint” cite. For example, the decisions of the federal appellate courts of the United States, including the Court of Appeals for the Federal Circuit located in Washington, D.C., are gathered in a Westlaw reporter known as the “federal” reporter. Currently this reporter is in its third series, and is indicated by the symbol “F.3d.” For example, the case citation to the Federal Circuit's landmark 1995 decision on claim construction is commonly written as Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir. 1995). The number preceding the “F.3d” is the volume number of the reporter in which the case is published, and the number following the “F.3d” is the page number where the decision starts within the volume of the reporter. In order to cite to specific text using a pinpoint cite, a third page number is typically added. For example, if one wanted to cite to the specific location in the decision at which the Federal Circuit held that the interpretation and construction of patent claims “is a matter of law,” that appears on page 970 in the reporter and the citation would commonly be written as Markman v. Westview Instruments, Inc., 52 F.3d 967, 970 (Fed. Cir. 1995). Other reporter systems use similar citation systems.
The problem with these prior art citation systems is that they depend upon the placement of the article or legal decision in a particular volume of a reporter, and starting at a particular page number within the particular volume of the reporter, both of which are somewhat arbitrary. Moreover, depending upon the formatting, line spacing, and font size used in the reporter, the article or legal decision could occupy different numbers of pages. Thus, the location of a pinpoint cite within the article or legal decision using these prior art citation systems is also somewhat arbitrary depending upon how many pages the article or legal decision occupies within the reporter. Because of these problems, it is not possible to use these prior art reporter systems to cite an article or legal decision until the publisher determines which volume of the reporter will contain the article or legal decision, and the page numbers within the particular chosen volume at which the article or legal decision will be located. This process of locating the article or decision within a reporter by the publisher can often take weeks or months after the date the article or legal decision is completed and made public, thus requiring the use of an alternate or temporary citation system if one wishes to cite to a recently issued article or legal decision.
Moreover, in order to use these prior art citation systems, one must first determine the correct volume and page numbers for the particular reporter in which the article or decision appears (or the temporary arbitrary decision number assigned to the newly-issued decision). This process consumes additional time and generally requires access to proprietary search databases maintained by the publishers of the reporters, who charge relatively high fees for such access. Many users of these legal citation systems are troubled by the fact that they must pay private enterprises for access to the proprietary search databases of legal decisions merely to obtain the arbitrary volume and page numbers of the reporter (or the arbitrary temporary decision number) needed to cite to the legal decision, when the legal decisions themselves are publicly available documents generated by the various taxpayer-supported state and federal courts of the United States. For example, the legal decisions of the Court of Appeals for the Federal Circuit are generally available on that court's public website the day they are issued. However, in order to use these prior art citation systems, one must access a proprietary database in order to determine the volume and page numbers of the federal reporter in which the decision appears, which often are not available until weeks after the decision is issued. In such instances, as discussed above, a temporary and also arbitrary alternate citation number is the only one available. Thus, the user must often repeat the search process at a later date, often paying additional fees, in order to obtain the permanent citation information for the same legal decision.